Register description

1. Data controller2. Person responsible for register matters and/or contact person 3. Name of the register4. What your personal data is used for5. What kind of personal data we collect about you6. Regular sources of data7. How we use cookies8. To whom we disclose your personal data9. Do we transfer your personal data outside the EU10. How long your data is retained11. How your personal data is protected12. Your rights as our customer13. Can this privacy statement be changed

Oy Vig Huolto-Service Ab Co Alkemax Sannaistenkatu 8 06100 Porvoo caddiemaster@virvikgolf.fi business ID: 2476123-4

Mikko Rintalamikko.rintala@vighs.fi

Customer data register based on a customer relationship with Virvik Golf and on other relevant connection.

Management, analysis and development of customer, member and stakeholder relationships · Provision and development of products and services · Delivery, processing and archiving of orders · Analytics and statistical purposes · Implementation and monitoring of customer, member and marketing communications. · Processing, analysis and compilation of statistics on customer feedback and on the results of customer surveys and studies. · Prevention and investigation of misuse and problem situations.

The legal basis for the processing of personal data under the EU General Data Protection Regulation is one of the following

the person's consent · a contract · a statutory obligation · legitimate interest

The register may contain the following data and information on changes to it:

Basic customer details

name details · contact details (postal address, email addresses, telephone numbers) · gender · date of birth · information concerning the profession or position in the work community of contact persons of corporate customers · identifiers that identify the customer · personal identity code · customer number · registration data concerning the data controller's services (e.g. usernames and passwords for the online store and the back-end system service) · identifiers used in targeting marketing

Data relating to the customer relationship and other relevant connection and to the use of services and content, such as:

data concerning purchases, such as data on the products and services purchased, including product warranty information, as well as the necessary data concerning payment, invoicing and debt collection, such as credit card details · data relating to the use of products · feedback and complaints · data on participants in events and training · location data (if the customer has given express permission for this) · browsing data and other data concerning the use of the data controller's electronic services and content, including the technical data sent by the data subject's browser to the data controller's server (IP address, browser) as well as the cookies sent to the data subject's browser and the data related to them, if personal data is attached to the cookies · data related to marketing and sales promotion, such as marketing measures directed at the data subject, the use made of them and the information given in connection with them, as well as direct marketing permissions and prohibitions · recordings of customer service calls as well as email and online conversations relating to customer service, for example in social media channels · Data relating to the customer is collected from the customer themselves when the contract is concluded, in the own details section of the online service, in connection with the use of products and services, in connection with customer service and when the customer takes part in product and service development, studies or surveys. · Personal data may also be collected and updated from other registers of the data controller and of the companies belonging to the same group as it at any given time, as well as from authorities and companies providing services concerning personal data, such as the Population Information System and other comparable registers. · We use cookies and other similar technologies, such as the browser's local storage, to provide and develop our services. We also use cookies to personalise content and to target advertising. Cookies allow us, among other things, to provide more up-to-date and individual services by displaying content based on the user's interests. They also make possible, for example, logging in and authentication, the saving of personal settings and configurations and the analysis of the operation of our sites. When you use our online services, they collect for example the following data: your IP address, which links you use, which advertisements or other content you have viewed, which page you come from and which you visit, the time of browsing, the type of your browser or application and other comparable data. · You can control the use of cookies for example through your browser's management functions. Further information on cookies is available in the privacy or help documentation of each browser. Certain features of the services depend on cookies, so blocking and deleting cookies (browser and other choices) may have an adverse effect on the functionality and user experience of the online or mobile application service in question.

Personal data may be disclosed only within the limits permitted and required by the legislation in force at any given time and in the manner required by the competent authorities. The data controller may share your personal data with carefully considered third parties for joint or independent direct marketing purposes. Data may be shared for those purposes only when the third party's intended purpose of use is not in conflict with the purposes of use defined in this privacy statement of the data controller.

The data controller may, at its discretion, share the personal data of persons taking part in the data controller's events with other participants in that event, if this is appropriate because of the nature of the event.

After the relevant connection has ended, the data controller may transfer data to its own direct marketing register within the limits permitted by law.

The data controller may share your personal data with third parties performing services for the data controller. Such services may include, for example, customer service, software services, research activities, marketing and event production. The data controller may share your personal data in order to collect payments for products and services, and it may, for example, transfer or sell unpaid invoices to third parties providing debt collection services.

Protecting your personal data is important to us, which is why it does not allow those parties to use the data for any purpose other than providing the services in question, and it requires the parties to protect the user's personal data in accordance with this privacy statement and applicable legislation

Personal data is not regularly disclosed for purposes other than those mentioned above. The data controller is, however, entitled in the manner permitted by legislation to disclose personal data, for example in situations relating to the sale of business operations. In addition, the data controller may disclose data for, among other things, statistical and analysis purposes in such a way that the disclosed data cannot be linked to an individual person.

In providing services, the data controller may use resources and servers located in different parts of the world. The data controller may therefore transfer your personal data outside the country of use of the services and possibly also to countries outside the EU area whose data protection legislation is different.In these cases the data controller ensures that there is a legal basis for the transfer of the data and that the user's personal data is protected, for example by using (where necessary) standard contractual clauses approved by the appropriate authorities and by requiring compliance with appropriate technical and other data protection measures

We retain your data at least for the duration of the customer relationship. After the customer relationship has ended, the retention period depends on the data and its purpose of use. For example, your customer due diligence data is retained for five years after the end of the customer relationship, and the data of potential customers is retained as a rule for six months from the collection of the data. We comply with statutory obligations in the retention of data.We strive to keep the personal data in our possession correct and up to date by deleting unnecessary data and by updating outdated data. We nevertheless encourage you to check from time to time that your data is up to date.

We protect your personal data with great care by using appropriate data protection and information security measures. Such measures include, among other things, proactive and reactive risk management, the use of firewalls, encryption techniques and secure equipment facilities as well as access control and security systems, security planning, controlled granting and monitoring of access rights, ensuring through training and assessments the competence of the personnel involved in the processing of personal data, and the careful selection of subcontractors. We continuously update our internal practices and instructions appropriately.

We are committed to processing data in accordance with the Data Protection Regulation and offer our users the following choices and control options relating to data protection:

Direct marketing prohibition

The user has the right to prohibit the disclosure and processing of their data for the purposes of direct advertising, distance selling and other direct marketing by contacting our customer service.